Susan Molloy’s Presentation to Access Board 5/23/18

Susan Molloy’s Presentation to U.S. Access Board at Phoenix Meeting on 5/23/18

U.S. Access Board

1331 “F” Street NW

Washington, DC 20004

Dear President Robertson, Board Members, and Executive Director Mr. Capozzi:

First of all, we are honored by your visit to ABILITY360, our Phoenix Disability Empowerment Center. Thank you, and ABILITY360 Executive Director Phil Pangrazzio, for all your efforts organizing this meeting and for hearing our presentations. Please extend our appreciation to your staff members as well for their hard work.

We trust that you are as encouraged as we, by which I mean people facing environmental barriers to public spaces and facilities, by the Indoor Environmental Quality (“IEQ”) Report of 2005. It was published by the National Institute of Building Sciences, sponsored by the U.S. Access Board, and coordinated by the Access Board’s then Chief Counsel Jim Raggio.

Through this project, we developed concepts and language through which to make the Access Board’s work more comprehensive.

While implementation of the measures we suggest in that document, and in subsequent communications, may not all be immediately achievable, it is our responsibility to see that inadvertent barriers to our access do not go unnoticed and that we assist the Board in drawing up applicable specifications and policies in accordance with the IEQ Final Report.

We are at your service to make this happen.

Toward that end, I endorse the presentations of Mary Lamielle, Director of the National Center for Environmental Strategies, of Ann McCampbell, M.D., from whom you have just heard, from Libby Kelley regarding electrical hypersensitivities and related issues, and from our other colleagues who have participated in preparation for this meeting.

Now, I would like to familiarize you with a few bare-bones features that can enormously and immediately improve our access to public places, with little or no expense, while more extensive measures are developed for future implementation.

SHORTLIST of Free, Readily Achievable Structural and Design Considerations

Windows that open (consider air-to-air heat exchanger technology)

Daylight, skylights, and the option of incandescent lightbulbs (no fluorescents or LEDS) in at least some specified areas of the facility

Landscaping using plants, trees, ground covers that require no chemical maintenance, and no extensive watering (to minimize mold growth)

Non-chemical IPM inside facility, paths of travel, and outdoors (sidewalks, parking area, bus stop)

No Fragrance Emission Devices (“FEDS”) in at least designated restrooms, and no fragrance distribution systems in Heating, Ventilation, Air Conditioning (“HVAC”) systems

No smart meters for electricity, gas, or water installed in public areas of a facility unless thoroughly and effectively shielded

Separate electrical wiring and/or fiber optics, and kill switches, for at least some areas of the facility so that non-essential computers, printers, fluorescents, others can be shut down without impacting other areas of the facility

No carpet in designated areas

Maintain existing landline phones, and re-install the old ones

Independent variable fresh air ventilation system (aka “fan”), for at least certain areas of the facility, that can be operated by the room occupant without assistance

Signage on and around the facility, in pertinent formats, indicating where accessible (for our purposes) sidewalks, ramps, doors, restrooms, phones, conference rooms, parking are located, along with a posted, readily available schedule of recent maintenance and materials

Signage, in pertinent formats, to designate areas where wi-fi is present, to prevent inadvertent exposure to the degree possible

Designation of areas for re-charging wheelchair batteries, cell phones, computers, vehicles, others using wired electrical outlets

Essential: buzzer or intercom outside the facility to summon building occupants such as the clerk, doctor, child, police, social services employee, grocer, shopkeeper

Study the “Cleaner Air Room” concept and language as per the Indoor Environmental Quality (“IEQ”) Report, pages 47-55, 2005, which is posted on the Access Board’s website (www.access-board.gov/research/building/indoor-environmental-quality)

Susan Molloy, M.A.

Hansa Trail, Snowflake, AZ 85937

928.536.4625

molloy@frontiernet.net